GRIEVANCE REDRESSAL POLICY

For Merchants, Corporates, Aggregators, Distributors & End Customers

Last Updated: April 2026

1. Preamble and Introduction

Fingpay is the brand name of Tapits Technologies Pvt. Ltd. (CIN: U72900MP2016PTC040639), a company duly incorporated under the Companies Act, 2013, having its registered office at 20 Dhenu Market, Indore – 452003, Madhya Pradesh, India. Fingpay is authorised by the Reserve Bank of India (RBI) as a Payment Aggregator (PA) for both online and physical payment modes, in accordance with the RBI Guidelines on Regulation of Payment Aggregators and Payment Gateways.

Fingpay holds certifications including PCI-DSS, ISO 27001:2013, and is compliant with Regulatory standards, underscoring its commitment to secure, reliable, and responsible payment infrastructure.

As a regulated payment intermediary, Fingpay recognises that effective, fair, and time-bound grievance redressal is both a regulatory obligation and a cornerstone of its service commitment. This Grievance Redressal Policy (“Policy”) is established to provide a structured and transparent mechanism through which any person or entity interacting with Fingpay’s platforms and services may raise concerns, lodge complaints, and receive timely resolution.

This Policy is published in accordance with the RBI Banking Ombudsman Scheme, RBI PA/PG Guidelines, and NPCI Circular 46 (AePS Harmonisation of TAT – Customer Compensation Policy), and shall be made available on Fingpay’s website at www.fingpay.co.in.

2. Objective of This Policy

The objectives of this Policy are to:

• Provide Merchants, Corporates, Aggregators, Distributors, and End Customers with accessible, clear, and equitable mechanisms to register, escalate, and resolve grievances arising from the use of Fingpay’s products and services.
• Ensure that all grievances are acknowledged promptly, investigated fairly, and resolved within defined turnaround times.
• Promote transparency in the grievance resolution process by ensuring that complainants are kept informed of the status and outcome of their complaint.
• Uphold the principle of 
• non-discrimination — that no person shall be treated less favourably in the grievance process on account of caste, creed, race, gender, religion, disability, or any other such characteristic.
• Align Fingpay’s internal complaint handling processes with applicable regulatory guidelines issued by the RBI and NPCI.
• Facilitate escalation to the RBI Digital Payments Ombudsman where internal resolution has not been achieved.

3. Scope and Applicability

3.1  Persons Covered

This Policy applies to the following categories of persons and entities who interact with Fingpay’s products and services:

• Merchants (individual and enterprise) onboarded on Fingpay’s payment platform
• Corporates and B2B Enterprises utilising Fingpay’s payment infrastructure
• Aggregators and Sub-Aggregators accessing Fingpay’s APIs
• Distributors and Channel Partners within Fingpay’s network
• End Customers transacting through Fingpay-powered merchant platforms
• BFSI clients, SME/MSME entities, and Corporate Business Correspondent (BC) networks

3.2  Services Covered

This Policy covers all products and services offered by Fingpay, including but not limited to:

• Aadhaar Enabled Payment System (AEPS)
• Micro ATM (mATM) and mPOS
• BHIM Aadhaar Pay
• UPI — Static/Dynamic QR, Intent-based Payments, and UPI Payment Links
• Payment Gateway — Cards (Credit/Debit), Net Banking, Wallets, and Mandates
• Bharat Bill Payment System (BBPS)
• Cash Management Services (CMS)
• KYC and Onboarding APIs
• Bank Account Verification
• Virtual Accounts
• Agent/Customer Collection Applications and SDKs

3.3  What Constitutes a Grievance

A grievance is any expression of dissatisfaction, complaint, or concern raised by a complainant in connection with Fingpay’s services, including but not limited to:

• Failed, pending, or disputed financial transactions
• Settlement delays or incorrect settlement amounts
• Refund failures or delays
• Service disruptions or platform downtime
• Errors in onboarding, KYC, or API integration
• Concerns regarding customer service quality or responsiveness
• Any matter for which redressal is sought

4. How to Register a Grievance

4.1  Grievance Channels

Complainants may register a grievance through any of the following channels:

4.2  Information Required with a Complaint

To facilitate prompt investigation and resolution, complainants are required to provide the following details at the time of registering a grievance:

1. Full name and contact details (email address and mobile number) of the complainant or authorised representative
2. Merchant ID, Aggregator ID, or Account Number, as applicable
3. Product or Service Name (e.g., AEPS, UPI, Payment Gateway, mATM, BBPS)
4. Transaction Date and Time
5. Transaction Reference/ID or UTR Number
6. Transaction Amount
7. A clear description of the complaint, including the nature of the issue and any prior communication reference
8. Any supporting documentation (e.g., transaction receipts, screenshots, bank statements)

Fingpay reserves the right to seek additional information or documentation as may be necessary for a fair investigation. Failure to provide required information may delay resolution.

4.3  Complaint Acknowledgement

Upon receipt of a grievance, Fingpay shall revert via email to the complainant within [6] working hours of receipt. This email shall be used for all subsequent communications and tracking. 

5. Escalation Matrix

The following escalation matrix defines the levels of complaint resolution, the designated points of contact at each level, applicable turnaround times, and the conditions that trigger escalation to the next level.

Notes on Escalation:

• Complainants should always attempt resolution at L1 before escalating to L2 or L3.
• Escalation to the next level is permissible only after the TAT at the preceding level has elapsed without satisfactory resolution, or if the complainant is dissatisfied with the resolution provided.
• The Nodal Officer (L3) has the authority to make final decisions on behalf of Fingpay in respect of grievances under this Policy.
• Working days exclude Sundays and public holidays as notified by the Government of India / Reserve Bank of India.

6. Turnaround Time (TAT) Grid by Complaint Type

TheTurn-Around Time (TAT) for resolving failed transactions, as outlined in the RBI’s instructions (circular DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019), will be strictly adhered to and adequately implemented

Note: The above TATs represent maximum resolution timelines. Fingpay shall endeavour to resolve complaints at the earliest practicable time within the applicable TAT. TATs are measured in working days, excluding Sundays and RBI-notified public holidays.

7. Complaint Tracking and Interim Updates

7.1 Obligation to Provide Interim Updates

Where resolution of a complaint is likely to exceed the applicable TAT specified in the TAT Grid (Section 6), Fingpay shall:

• Proactively notify the complainant of the reason for the delay and the revised expected resolution date.
• Provide interim status updates at least every 
• [3] working days until the complaint is resolved.
• Ensure that a complaint is never closed without the complainant’s acknowledgement of resolution, except in cases where the complainant is unresponsive after [3] follow-up attempts over [7] working days.

8. Compensation Policy

Compensation for failed or disputed transactions, including the determination of applicability, eligible scenarios, and associated turnaround timelines, shall be governed in accordance with the Reserve Bank of India circular bearing reference DPSS.CO.PD No. 629/02.01.014/2019-20 dated September 20, 2019, titled ‘Harmonization of Turn Around Time (TAT) and customer compensation for failed transactions using authorised Payment Systems’, and any amendments, clarifications, or re-enactments issued thereto from time to time. The provisions of the aforesaid circular shall be deemed to form an integral part of this Policy for the purposes of compensation.

9. 9.  Role of the Nodal Officer

9.1  Appointment and Authority

In compliance with the RBI PA/PG Guidelines, Fingpay has designated a Nodal Officer responsible for overseeing the implementation of this Policy, supervising the grievance redressal mechanism, and ensuring regulatory compliance in all matters relating to customer complaints.

9.2  Current Nodal Officer

9.3  Responsibilities of the Nodal Officer

• Supervise and monitor the overall grievance redressal process across all levels.
• Review and decide on complaints escalated to L3 within the prescribed TAT of 1 working day.
• Liaise with relevant internal departments (Technology, Operations, Finance, Compliance) to ensure prompt investigation and resolution.
• Maintain a record of all complaints received, escalations made, and resolutions communicated.
• Prepare periodic reports on grievance trends and recommend process improvements.
• Serve as the primary point of contact for the RBI and other regulatory authorities in matters relating to complaints and grievance redressal.
• Ensure compliance with all regulatory directives related to grievance handling, including NPCI Circular 46 and RBI PA/PG Guidelines.

10. Digital Payments Ombudsman / RBI Escalation

10.1  Right to Approach the Ombudsman

If a complainant’s grievance remains unresolved by Fingpay, or if the complainant is dissatisfied with the final resolution provided, the complainant has the right to escalate the matter to the RBI Digital Payments Ombudsman (DPO) in accordance with the RBI Integrated Ombudsman Scheme.

10.2  Conditions for Approaching the Ombudsman

A complainant may approach the RBI Digital Payments Ombudsman only if:

• The complaint has been lodged with Fingpay and Fingpay has not resolved it within 30 (thirty) calendar days of receipt; or
• The complainant is not satisfied with the resolution provided by Fingpay at any level of the escalation matrix.

The complainant must lodge the complaint with Fingpay first and allow a minimum period of 30 days for resolution before approaching the Ombudsman, except in exceptional circumstances.

10.3  Contact Details — RBI Digital Payments Ombudsman

Note: The Digital Payments Ombudsman mechanism is a no-cost escalation channel available to complainants. Fingpay will co-operate fully with any inquiry or directive issued by the Ombudsman.

11. Review and Updates to This Policy

This Policy shall be reviewed at least once every financial year or earlier, if required by:

• Changes in RBI or NPCI regulatory guidelines applicable to Payment Aggregators;
• Significant changes to Fingpay’s products, services, or operational processes;
• Feedback from internal review of grievance trends or resolution effectiveness;
• Directions or recommendations from regulatory or audit bodies.

Any material amendments to this Policy will be communicated to registered merchants, aggregators, and partners via email notification and/or publication on Fingpay’s official website at www.fingpay.co.in. The revised Policy will indicate the updated “Last Updated” date at the top of the document. Continued use of Fingpay’s services after the effective date of any revised Policy shall constitute acceptance of the revised terms.

For details on data handling, privacy practices, and information security, please refer to Fingpay’s Privacy Policy, available at www.fingpay.co.in/privacy-policy.

12. Governing Law and Jurisdiction

This Policy shall be governed by and construed in accordance with the laws of the Republic of India, including the Information Technology Act, 2000 (as amended), the Payment and Settlement Systems Act, 2007, and all applicable RBI and NPCI regulations and circulars.

Any dispute arising out of or in connection with this Policy that is not resolved through the grievance mechanism described herein shall be subject to the exclusive jurisdiction of the courts of Indore, Madhya Pradesh, India, at the sole discretion of Fingpay.

Nothing in this clause shall limit the rights of any complainant to approach the RBI Digital Payments Ombudsman as specified in Section 10 of this Policy.